Pre-emptive purchase procedure: lack of prior notice or reasons will not undo a completed and accepted transaction.

Chapter XX-C pre-emptive purchase proceedings require a reasonable opportunity of hearing and disclosure of the valuation basis before compulsory purchase is ordered. However, procedural objections on notice and recorded reasons do not invalidate the purchase where the transaction has already been completed, the consideration has been returned without protest, and possession has been taken. In that situation, the completed and acted-upon transaction is not unsettled by challenge to the purchase order. The writ petitions were dismissed, and the challenge failed because the transaction had been fully carried through and accepted.

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Issues: Whether the order of pre-emptive purchase under Chapter XX-C of the Income-tax Act, 1961 was liable to be quashed for want of stated reasons and prior opportunity of hearing, and whether the challenge survived when the transaction had already been completed.

Analysis: The statutory scheme under Chapter XX-C and Section 269UD(1) requires that persons likely to be affected be given a reasonable opportunity before compulsory purchase is ordered, and the decision-making process must disclose the basis of valuation. However, the controlling principle applied was that this requirement does not unsettle completed transactions where the purchase has been acted upon, consideration has been received back without protest, and possession has been taken. In such circumstances, the absence of supplied reasons or prior notice does not furnish a ground to invalidate the purchase order.

Conclusion: The challenge failed, and the writ petitions were dismissed.

Final Conclusion: The decision holds that procedural objections based on notice and reasons cannot undo a concluded pre-emptive purchase transaction that has been fully acted upon.

Ratio Decidendi: The requirement of prior hearing and recorded reasons in compulsory purchase proceedings under Chapter XX-C does not invalidate a transaction that has already been completed and accepted without protest.

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